Calyx Private Office LLP (UK company registered in England and Wales under number OC430514) will comply with the applicable provisions of the Data Protection Act 1998 as amended from time to time (“the DPA”) and, to the extent applicable, the EU General Data Protection Regulation, and will not process any personal data or sensitive data in a manner incompatible or inconsistent with the purposes for which that information has been provided to us (“Personal Data”) under this Privacy & Cookies Policy.
You may provide us with personal information which means information about a living individual who can be identified from that information (either by itself or when it is combined with other information).
We may update our Privacy Notice from time to time, by communicating changes to you and publishing the updated Privacy Notice on our website. We would encourage you to visit our website regularly to stay informed of the purposes for which we process your information and your rights to control how we process it.
INFORMATION WE COLLECT AND USE
Information about you that we collect and use includes:
- Information about who you are e.g. your name, date of birth and contact details.
- Information connected to your product or service with us e.g. your bank account details.
- Information about your contact with us e.g. meetings, phone calls, emails / letters.
- Information that is automatically collected e.g. via cookies when you visit our website.
- Information if you visit our office e.g. visual images collected via closed circuit television (CCTV).
- Information classified as ‘special category’ personal information e.g. relating to your health.
- Information you may provide us about other people e.g. joint applicants or beneficiaries, for services or products you have with us.
- Children are not able to buy services or products from us. However, on instruction from a parent or guardian, a child can be named as a beneficiary on some trusts and funds. In these cases, we collect relevant personal information to identify the child (such as their name and age).
Where we collect and use special category personal information, this information will only be collected and used where it is needed to provide the appropriate service or product to you or to comply with our legal obligations, and where we have also obtained your explicit consent to process such information.
HOW WE OBTAIN YOUR INFORMATION
We may collect your personal information directly from you, from a variety of sources, including:
- An application form for a service.
- Telephone conversations with us.
- Emails or letters you send to us.
- Meetings with a member of the Calyx team.
If you have a financial adviser the information we collect and use may have been provided by them on your behalf.
We may also collect personal information about you from places such as business directories and other commercially or publicly available sources e.g. to check or improve the information we hold (like your address).
Why we collect and use your information
We take your privacy seriously and we will only ever collect and use information which is personal to you where it is necessary, fair and lawful to do so. We will collect and use your information only if we are able to satisfy one of the lawful processing conditions set out in the data protection laws. This will be the case where:
- It is necessary to provide services or products you have requested e.g. to provide you with an investment portfolio tailored to your specific needs, we will require some personal information which may include your name, address, date of birth, and bank account details and may also collect some sensitive information.
- It is necessary for us to meet our legal or regulatory obligations e.g. to send you statements, tell you about changes to Terms and Conditions, or for the detection and prevention of fraud.
- It is in the legitimate interests of Calyx.
- to deliver appropriate information and guidance so you are aware of further options available to you to support a better outcome from your services with Calyx.
- to process your information to better understand you and your needs so we can send you more relevant communications about our services and products you have with us and to develop new services and products.
- Where the processing is in our legitimate interests, we will always conduct an assessment to ensure that this use of your personal information is not excessive or unnecessary or otherwise more intrusive than it needs to be.
- You have given us your consent to use your information. For example, if we are collecting and using your special category personal information or to send you information which we believe may be of interest and benefit to you. This could be about products and services offered by selected third parties we have chosen to work with.
You can withdraw your consent at any time by contacting us through your Relationship Manager.
Who we share your information with and why
We may share your information internally and with third parties for the reasons outlined in ‘Why we collect and use your information’.
We will share your information with:
Other companies who support us in the provision of services to you or products you have.
Credit and identity check agencies for ID verification and credit reference checks.
Your adviser, trustee, business associate, professional advisor where this is required as part of the service or product you have agreed with us.
Companies we have chosen to support us in the delivery of the services or products we offer to you and other clients. For example, custodians, administrators, investment platforms, research, consultancy or technology companies who help us improve our service to you.
Companies who can help us in our contact with you, for example an internet service provider.
Law enforcement and other appointed agencies who support us (or where they request the information) in the prevention and detection of crime.
Whenever we share your personal information, we will do so in line with our obligations to keep your information safe and secure.
How we protect your information
We take information and system security very seriously and we strive to comply with our obligations at all times. Any personal information and special category personal information which is collected, recorded or used in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection obligations.
Your information is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. Our employees protect special category or confidential information when storing or transmitting information electronically.
Our security controls are aligned to industry standards and good practice providing a control environment that effectively manages risks to the confidentiality, integrity and availability of your information.
How long we keep your information
To provide your service or product, and meet our legal and regulatory obligations, we keep your personal information and copies of records we create (e.g. calls with us) while you are a client of ours.
Even when you no longer have a relationship with us, we are required to keep information for different legal and regulatory reasons. The length of time will vary and we regularly review our retention periods to make sure they comply with all laws and regulations.
HOW WE USE AND SHARE INFORMATION WITH NEMESIS ASSET MANAGEMENT LLP
We will only use and share our information where it is necessary for us to lawfully carry out our business activities. Your information may be shared with and processed by Nemesis Asset Management LLP, our Principal firm.
Nemesis Asset Management LLP is authorised and regulated by the Financial Conduct Authority (211205).
You have a number of rights under the Data Protection Laws in relation to the way we process your personal data, which are set out below. If you wish to exercise any of these rights, or if you have queries about how we use your personal information which are not answered here, please contact Stacy Iervolino on the following email address: email@example.com or by post at:
Calyx Private Office LLP
42 Brook Street
London W1K 5DB
We will aim to respond to any request received from you in relation to exercising your rights within one month from your request, although this may be extended in some circumstances in line with Data Protection Laws.
Your Legal Rights
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email us at firstname.lastname@example.org or contact us by post at:
Calyx Private Office LLP
42 Brook Street
London W1K 5DB
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
Right to request that your personal information be rectified
If your personal information is inaccurate or incomplete, you can request that it is corrected.
Right to request erasure
You can ask for your information to be deleted or removed if there is not a compelling reason for Calyx to continue to have it.
Right to restrict processing
You can ask that we block or suppress the processing of your personal information for certain reasons. This means that we are still permitted to keep your information – but only to ensure we don’t use it in the future for those reasons you have restricted.
Right to data portability
You can ask for a copy of your personal information for your own purposes to use across different services. In certain circumstances, you may move, copy or transfer the personal information we hold to another company in a safe and secure way. For example, if you were moving your assets to another bank.
Right to object
You have a right to object to us processing your personal information and to ask us to restrict processing, unless we can demonstrate compelling and legitimate grounds for the processing, which may override your own interests or where we need to process your information to investigate and protect us or others from legal claims.
Please note that if you object to us processing your information, we may have to suspend the operation of your account and/or products and services we provide to you.
You have the right to object at any time, to the processing of your personal information for direct marketing purposes, including profiling you for the purposes of direct marketing. You can tell us in writing at any time if you do not want to receive marketing information.
How to make a complaint
If you wish to raise a complaint about how we have handled your personal information, you can email us at email@example.com or by post: Calyx Private Office LLP, 42 Brook Street, London W1K 5DB who will investigate the matter. We hope that we can address any concerns you may have, but you have the right to complain directly to the Information Commissioner’s Office. You can contact them in writing at the following address:
Information Commissioner’s Office
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.